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V2137-17 18 August 2017 · SG de Fiscalidad Internacional Criterion in force
IRNR · establecimiento permanente

Hispanic-Colombian double taxation treaty applies to interest paid by Colombian company to Spanish financial entity

A Colombian company asks whether the Spain-Colombia treaty to avoid double taxation applies to a loan obtained from a Spanish bank branch in the US. The DGT confirms that it does, as the branch lacks independent legal personality and the bank is a Spanish tax resident.

The question raised

Question posed: Is the Spanish-Colombian Double Taxation Convention applicable to the relationships between the applicant and the bank branch?

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What is published here, applied to a company or a specific case. The first meeting is free.

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